United States securities and exchange commission logo

                             February 17, 2021

       Joseph D. Vittiglio
       General Counsel and Corporate Secretary
       Finch Therapeutics Group, Inc.
       200 Inner Belt Road, Suite 400
       Somerville, Massachusetts 02143

                                                        Re: Finch Therapeutics
Group, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted February
9, 2021
                                                            CIK No. 0001733257

       Dear Mr. Vittiglio:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Amendment No. 1 to Draft Registration Statement on Form S-1, Filed
February 9, 2021

       Prospectus Summary
       Overview, page 1

   1.                                                   We note your response
to our prior comment 2 and the related revisions to the prospectus;
                                                        however, the disclosure
still contains statements suggesting your product candidates are
                                                        safe or effective.
Please revise such statements, including, as examples only, the

                                                                 CP101 is the
only orally administered, microbiome therapeutic candidate drug in
                                                            development with
positive pivotal data demonstrating clinical efficacy in all stages of
                                                            recurrent CDI.
 Joseph D. Vittiglio
Finch Therapeutics Group, Inc.
February 17, 2021
Page 2
                   CP101 has also demonstrated efficacy among patients
diagnosed by either
              polymerase chain reaction.
                   In addition to demonstrating robust efficacy through the
8-week endpoint, a post-
              hoc analysis demonstrated that CP101   s efficacy was robust over
                   We used data from these clinical trials to confirm potential
mechanisms underlying
              the clinical efficacy observed with CP101 for recurrent CDI.
                    Data from over 40 FMT studies, including four randomized,
              trials in ulcerative colitis and one randomized,
placebo-controlled trial in Crohn   s
              disease, have shown promising clinical efficacy with a favorable
safety profile.
                    Based on the data we have generated with CP101 in recurrent
CDI, where we have
              shown a favorable safety and efficacy profile   .

         We remind you that determinations of safety and efficacy are solely
within the purview of
         the FDA and not within the control of the company; therefore,
favorable determinations
         should not be implied or assumed.
2.       We note your response to our prior comment 4 and your expanded Summary
risk factor
         disclosure that three of the company's competitors have a product
candidate being
         evaluated in clinical trials for recurrent CDI. In light of this
disclosure, please clarify your
         support for the statements that you are the only company with
capabilities to pursue both
         targeted and enriched consortia, CP101 is the first orally
administered, microbiome
         therapeutic candidate to meet its primary endpoint in a pivotal trial,
and that you have the
         first and only late-stage, orally administered Complete Consortia
product candidate.
Our Approach, page 109

3.       We note your response to our prior comment number 10. Please remove
the reference to
            potential first-in-class    product candidates like FIN-211 on page
111. This term may be
         interpreted to suggest that your product candidate has been or will be
approved by the

4.     We note that Exhibits 10.3 through 10.7 contain redactions but have not
been marked as
       redacted in the Exhibit Index. In addition, the exhibits themselves do
not contain the
       appropriate heading indicating that redactions are contained. Please
revise the Exhibit
       Index to indicate the redactions and revise the exhibits to include a
prominent statement
FirstName LastNameJoseph D. Vittiglio
       on the first page that certain identified information has been excluded
from the exhibit
Comapany    NameFinch
       because  it is bothTherapeutics  Group,
                           (i) not material     Inc.would be competitively
harmful if publicly
                                            and (ii)
February  17, 2021See   Item
                     Page  2 601(b)(2)(ii) of Regulation S-K.
FirstName LastName
 Joseph D. Vittiglio
FirstName LastNameJoseph    D. Vittiglio
Finch Therapeutics  Group, Inc.
February   NameFinch
             2021      Therapeutics Group, Inc.
Page 3 17, 2021 Page 3
FirstName LastName
       You may contact Tara Harkins at 202-551-3639 or Kate Tillan at
202-551-3604 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Margaret Schwartz at 202-551-7153 or Laura Crotty at 202-551-7614 with
any other


                                                         Division of
Corporation Finance
                                                         Office of Life
cc:      Courtney T. Thorne, Esq.